HWEA: Northside Waste Water Treatment Plant - Executive Summary

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This executive summary will provide a brief description of the Northside Waste Water Treatment Plant's risk management program.  It will communicate the risks posed by the facility to the community and what we have done to minimize the risk.  HWEA and its employees have placed great effort and resources into the accident prevention program.  In addition, several new prevention programs are planned and will be completed in the near future.  Senior management is committed to safety and implementation. 
  The facility's overall approach to chemical safety is excellent.  For example,  several accidential release  prevention and emergency response policies have been written and reviewed by both internal and external sources.   These include: a written community emergency response plan, facility emergency response plan, procedures for informing the public, and emergency health care actions.  These plans are coordinated through the Christian County DES office and reviewed annually.        
 
Chlorine is the only regulated chemical stored in sufficent quantities and used in the production of treated water that requires compliance with EPA's Risk Management Plan(RMP).  Chlorine stored in excess of 2500 pounds in one process requires a RMP to be completed.  Chlorine is stored in 2 each 1-ton steel cylinders.  The cylinders meet or exceed Department of Transportation regulatory requirements.  The operators are provided with training and the proper equipment to safely and properly handle the chemical.   The chlorine system is a process that was designed and installed to prevent incidents. 
  This plan includes a worst case release scenario involving chlorine.  The analysis details the off-site impact based on the release of the total inventory within a ten minute duration as required by the RMP regulations.  The EPA computer model estimates the release would affect approximately 1000 members of the community with a distance of 1.30 miles from the source.  However, the actual r 
eleased amount of chlorine would be much less than the required estimate and scenerio making the worst-case release unlikely.  Passive mitigation systems such as the process enclosure would limit the release.  Also, the trained operations personnel and operating procedures would allow for a quick and successful response. The written procedures and area alarm systems would reduce the loss. 
  The plan also includes an alternative chlorine release.  A scenerio involving a leaking cylinder connection during its connection to the treatment process is more likely to address the severity of a release.  The alternative release involves the loss of one pound over a one minute duration.  This would affect approximately 250 members of the community within a 0.10 mile radius.  The release would be reduced due to the passive and active mitigation systems.  This includes an enclosed process system.    
  The waste water treatment facility is covered by several state and federal regulatory agency re 
quirements.  These include: OSHA, EPA, DOT, fire marshal and local fire department.  Various agency inspections are conducted during normal operations.  The prevention program includes many elements.  These include: process controls such as vents, relief valves, manual shutoffs, interlocks, alarms and procedures, emergency power, and backup pumps.  Process area monitors observe for any chlorine concentration and respond to the high levels.  Improved maintenance procedures and operating training are an important element.   
  The plant has not experienced any accidential releases during the five-year accident history.  The chlorine system was a factory designed system. This low accident rate proves the integrity of the process and its operations personnel.  
  An excellent emergency response program was developed and is maintained to meet or exceed all regulatory requirements.  For example, the response plan is reviewed by the local emergency response agency and all employees.  In addit 
ion, personnel receive ERT training, drills are conducted, and public notification and alert systems are in place to provide a quick response and minimize the impact.   
  A detailed process hazard review (PHR) is scheduled to begin during June.  The PHR will utilize acceptable industry techniques such as: what-ifs, checklists and what if/checklists.  The review will identify any process areas with opportunities for improvement.  The action items will be completed as soon as possible to ensure a safe system is provided. 
 In summary, HWEA and its employees strive to provide a safe and efficient waste water treatment facility.  Many systems are in place to prevent a chlorine release and limit the impact on the community.
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